Can "Hazard-Cost-Effectiveness Analysis" improve the risk management of chemicals under REACH?

Cost-Effectiveness Analysis (CEA) is a decision-making framework to prioritize policy decisions for chemicals. Differences in hazard profiles among chemicals are not integrated in CEA under the EU REACH Regulation, which could limit its relevance. Another concern is that two different economic decision support methods (CEA for chemicals considered as PBTs or vPvBs from a regulatory perspective and Cost Benefit Analysis (CBA) for others) are used under REACH. To address this situation, we define "Hazard" CEA by integrating a hazard score, based on persistence, bioaccumulation and (eco)toxicity, in the effect indicator of CEA. We test different designs and parameterizations of Hazard-CEA on a set of past socio-economic assessments under REACH for PBT and non-PBT chemicals. Weighing and thresholds in hazard scores do not have a significant impact on the outcome of Hazard-CEA but the design of the hazard scoring method does. We suggest using an integrated and unweighted scoring method with a multiplicative formulation based on the notion of risk. Hazard-CEA could be used for both PBT and non-PBT chemicals, to use a single method in REACH and therefore improve consistency in policy decisions. Our work also suggests that using Hazard-CEA could help make decision easier.

Costs and benefits of recycling PVC contaminated with the legacy hazardous plasticizer DEHP.

Reusing materials is an attractive option for circular economy and can also reduce emissions of greenhouse gases and pollutants. However, recycling raises questions regarding the potential risks to human health or the environment when hazardous legacy chemical additives of materials are also recycled, instead of the recent and less hazardous additives of virgin materials. To address this trade-off, this study developed a model to calculate the total external cost of material supply, considering the health and environmental impacts of all industrial steps (e.g. virgin material production, incineration, and recycling), and the health effects of recycling chemicals present in the material. The model is coupling material flow analysis, life-cycle analysis, and environmental economics to compare different recycling policies. It is applied for all illustrative purposes to soft PVC and DEHP in France. Results show that recycling of materials is in the long-term positive despite the prolongation of the presence of hazardous additives in materials. The time when the recurring environmental benefits of recycling offset the negative impacts on human health of recycling the additives is very sensitive to the health impact of additives. This approach can improve the harmonization between recycling and circular economy policies, and as a framework to confirm the relevance and size treatments to remove additives from materials during recycling.

Non-persistent chemicals in polymer and non-polymer products can cause persistent environmental contamination: evidence with DEHP in Europe.

Bis(2-ethylhexyl) phthalate (DEHP) is a plasticizer that has been massively used since the second part of the twentieth century by the plastic industry to provide softness properties to PVC. This chemical is considered as toxic to reproduction and endocrine disrupting, and a wide range of uses are now forbidden by the EU. Despite these regulations, DEHP is still found to be a widespread contaminant in watersheds in the EU. In this study, we calculate retrospective and prospective scenarios of past and future emissions of DEHP in the environment (water, soil, air) in the EU 28, taking into account the entire lifecycle of the substance, from its production and its inclusion in polymer (mainly PVC) and non-polymer products (adhesive and sealant, ceramic and printing ink) to the recycling and end of life of these products. We develop a stock and flow model based on dynamically estimating the stocks of DEHP present in products on the market. Our results show that the introduction of recent regulations to limit the use of DEHP (that bring a 70% reduction of DEHP contained in products placed on the market in 2020 and 75% in 2040) will not reduce significantly future emissions. This persistence of emissions is explained by the high stocks built in the economy and the long-term presence of soft PVC waste in landfills. Our results suggest that DEHP will remain a cause of environmental contamination many decades after uses have declined and even ceased, and it appears to be too late for market regulation at the market stage to offset the effect of past stock buildup and landfilling. It is likely that several chemicals that are not considered as persistent and therefore not the focus of international regulations could exhibit the same characteristics. Regulations should avoid possible use patterns that make hazardous chemicals persistent in products, because they have the potential to create long-term and almost irreversible environmental pollution and impacts.

Integrative approach in a safe by design context combining risk, life cycle and socio-economic assessment for safer and sustainable nanomaterials.

Moving towards safe and sustainable innovations is an international policy ambition. In the on-hand manuscript, a concept combining safe by design and sustainability was implemented through the integration of human and environmental risk assessment, life cycle assessment as well as an assessment of the economic viability. The result is a nested and iterative process in form of a decision tree that integrates these three elements in order to achieve sustainable, safe and competitive materials, products or services. This approach, embedded into the stage-gate-model for safe by design, allows to reduce the uncertainty related to the assessment of risks and impacts by improving the quality of the data collected along each stage. In the second part of the manuscript, the application is shown for a case study dealing with the application of nanoparticles for Li-Ion batteries. One of the general conclusions out of this case study is that data gaps are a key aspect in view of the reliability of the results.